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Union framework for the calculation of life-cycle Global Warming Potential for new buildings

Energy

According to Article 7(3) of the EPBD recast (Directive (EU) 2024/1275), the European Commission shall adopt a delegated act to set out a Union framework for the national calculation of life-cycle Global Warming Potential for new buildings. The objective is to make comparable the national values for the life-cycle Global Warming Potential, which will have to be calculated for all new buildings as of 2030.

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Public consultation

ID: 14604

Lobbying Activity

47 responses

European Environmental Bureau calls for harmonised EU building carbon limits

European Environmental Bureau, 31 Oct 2025

The organization requests that minimum requirements for life cycle stages, physical scope and methodology apply to both reporting and setting of limit values. They recommend making modules B5 and B7 mandatory and reporting Module D separately to avoid offsetting.
This would create harmonised standards across EU member states while maintaining their flexibility.

Microsoft Urges Streamlined EU Data Center Climate Rules

Microsoft Corporation, 31 Oct 2025

Microsoft requests avoiding regulatory overlaps between the Energy Performance of Buildings Directive, Energy Efficiency Directive, and upcoming EU Rating Scheme for Data Centers. They propose either exempting data centers from building-oriented EPBD requirements or aligning EPBD methodology with EED metrics. They also advocate for harmonized treatment of operational water consumption and capacity-based performance metrics instead of per-square-meter measurements.
This would reduce compliance costs and avoid conflicting efficiency standards across multiple EU directives.
Environmental advocates lose comprehensive building-level assessments that capture total facility carbon footprint.

Siemens Urges Digital Standards to Streamline EU Building Carbon Assessments

Siemens AG, 30 Oct 2025

Siemens requests integration of the Asset Administration Shell digital standard into EU building regulations. They argue this would enable standardized, machine-readable data exchange for carbon calculations and reduce administrative burdens.
This would position Siemens' Industry 4.0 digital framework as a standard for EU building data.

Finnish Energy Urges Forward-Looking Emission Factors in Building Climate Calculations

Finnish Energy - Energiateollisuus ry, 31 Oct 2025

The organization requests that emission factors reflect future energy system changes rather than historical data. They argue this ensures fair comparison between heating technologies and incentivizes cleaner solutions.
This would prevent their district heating systems from appearing less favorable under national averages.

Ceramic Industry Backs EU Building Carbon Framework with Long-Term Focus

European Ceramic Industry Association, 23 Oct 2025

The organization supports the harmonized EU calculation framework but requests a 100-year reference period instead of 50 years to promote durable construction. They want Member States to have flexibility in considering benefits of long-lasting buildings and recommend using gross floor area definitions.
This would better showcase the environmental benefits of durable ceramic materials in buildings.

Bouygues urges EU to strengthen building carbon rules

BOUYGUES EUROPE, 31 Oct 2025

The company requests stricter product data standards using EN 15804 A2, making refurbishment and water use calculations mandatory, and adopting the B1 approach for renewable energy calculations. They want zero emissions assigned to reused construction products.
This would create competitive advantage from their French RE2020 experience and boost their reuse practices.

Plastics Europe urges fair life-cycle carbon accounting for building materials

Plastics Europe, 30 Oct 2025

The organization requests that operational energy use be mandatory and that end-of-life stages account for full carbon release from biogenic materials. They want manufacturers to use verified product-specific service life data and recognition of all recycling pathways including chemical recycling.
This would reward their durable plastic insulation products and avoid undervaluing their permanent GWP savings.
Biogenic materials producers lose if their end-of-life carbon release is fully accounted for.

Metsä Group urges EU to recognize wood's carbon storage

Metsäliitto Cooperative, 31 Oct 2025

Metsä Group wants the regulation to explicitly recognise biogenic carbon storage and allow for dynamic assessments. They demand EU-wide mutual recognition of environmental data to prevent market fragmentation and protect smaller businesses. The proposal should include a mandatory roll-up calculation to ensure verifiable traceability.
A framework rewarding biogenic carbon would boost demand for their wood-based construction products.
Mineral-based material producers may lose market share if carbon accounting heavily favors wood.

Environmental Coalition Urges Stronger Life-Cycle Assessment Rules for Buildings

Environmental Coalition on Standards, 20 Oct 2025

The organization supports establishing a data hierarchy that incentivizes producers to develop primary environmental data. They request that Member State methodologies be validated by the Commission and remain compatible with EN15804. They also call for mandatory assessment of all life-cycle stages including B5 and B7 modules.
This would strengthen environmental standards and ensure consistent assessment across Member States.
Building industry loses flexibility to exclude certain assessment modules from life-cycle calculations.

Schwarz Group calls for simplified EU building carbon rules

Schwarz Corporate Affairs International GmbH, 31 Oct 2025

The group demands maximum possible harmonisation of the methodology to avoid complexity and costs. They want to explicitly reject the inclusion of components that fall under user-specific fit-out. They also oppose the use of conservative standard values combined with a penalty factor.
Harmonisation would reduce the unnecessary complexity and increased costs of national rules.
Environmental groups lose oversight if the framework removes conservative estimates for missing data.

Efficient Buildings Europe Calls for EU-Wide Data Standards in Carbon Rules

Efficient Buildings Europe, 31 Oct 2025

The organization requests that the rules prioritize primary product data from verified declarations and EU-level generic data rather than national-level data. They want harmonized product-level data for HVAC manufacturers and explicit recognition of Ecodesign data sources.
This would reduce administrative burden by avoiding different datasets for varying national standards.

FIEC demands simpler EU rules for building emission calculations

European Construction Industry Federation, 31 Oct 2025

FIEC calls for a simplified framework that prioritizes high-impact materials. They request digital tools and generic data to reduce the reporting burden. They also want the rules limited to the existing energy directive scope.
This would significantly reduce the high administrative costs and labor required for compliance.
Environmental advocates lose detailed data on the footprint of secondary building infrastructure.

Bellona Europa urges mandatory emissions limits across all building lifecycle stages

Bellona Europa, 31 Oct 2025

The organization requests that all lifecycle stages be covered by mandatory limit values, not left optional to Member States. They propose creating an EU-wide database for generic data and including pre-construction demolition as required. They recommend introducing time-dependent coefficients to reward longer building lifespans over 50 years.
This would create lead markets for low-carbon construction products and reduce avoidable blind spots in emissions data.
Member States lose flexibility to exclude lifecycle stages from emissions limits and calculations.

European insulation industry urges harmonised building carbon calculation rules

European Insulation Manufacturers Association, 31 Oct 2025

EURIMA calls for a clear legislative commitment to align calculation scopes and prioritize producer-specific data. They recommend using the full life cycle as the primary performance metric.
Harmonized standards prevent insulation manufacturers from being penalized by incomplete emission calculations.
Fragmented national rules harm investors by increasing regulatory complexity and project costs.

Rockwool urges EU to harmonize building carbon emission standards

ROCKWOOL A/S, 31 Oct 2025

Use the latest standards and all life-cycle stages for uniform implementation across the EU. Prioritize verified product-specific data over inconsistent generic information or average values. Reward durability by reflecting strategies that extend building lifespans and reduce material turnover.
Consistent rules would prevent high-durability products from being unfairly penalized by short-term assessment models.
Producers of short-lived materials lose out when the framework rewards long-term durability and circularity.

VELUX urges prioritizing specific product data in building emissions rules

VELUX A/S (VELUX Group), 30 Oct 2025

VELUX requests that specific data from the Construction Products Regulation be prioritized over generic alternatives. They also seek clear guidelines for aligning ecodesign data with construction standards to ensure methodological consistency.
Prioritizing specific data would reward companies that invest in more sustainable product designs.
Cross-border manufacturers face market distortions if countries adopt inconsistent national data sets.

Knauf Insulation urges harmonized EU building carbon calculation standards

Knauf Insulation, 30 Oct 2025

Knauf requests a 'cradle to grave' approach for all emissions to ensure a holistic perspective. They advocate for prioritizing product-specific data and using the EN 15804 standard exclusively.
Harmonized standards protect the company’s competitiveness by preventing regulatory fragmentation across the Single Market.
National governments lose the flexibility to omit specific emission stages from their local regulations.

TNO Urges Fully Harmonized EU Building Emissions Framework

Netherlands Organisation for Applied Scientific Research TNO, 31 Oct 2025

TNO recommends a fully harmonized approach that minimizes specific national rules to allow borderless trade. They suggest setting the carbon footprint of reused materials to zero to promote circularity. The organization also proposes extending these assessment requirements to include large renovation projects.
This would reduce administrative burdens and the need for expensive re-certification in different countries.
National regulators would lose the power to maintain their own country-specific certification rules.

Glass for Europe calls for unified building carbon limits

Glass for Europe, 31 Oct 2025

The organization requests a consistent framework for setting carbon limit values across the EU. They propose updating reporting tables to show the total carbon impact from all construction stages.
Standardized rules would reduce the complexity of selling glass products across different European markets.
National governments lose the flexibility to set climate priorities based on their local construction methods.

European Heating Industry Urges Harmonized Building Carbon Standards

Association of the European Heating Industry, 31 Oct 2025

EHI requests a harmonized EU methodology for heating appliances under ecodesign regulations. They propose using both EN 15804 and EN 50 693 standards during the transition. Additionally, they suggest allowing data extrapolation within product families to simplify compliance.
Unified standards would lower administrative costs and prevent market fragmentation across Member States.
National authorities would lose the ability to mandate specific local environmental impact categories.

Swedish Steel Industry Urges Standardized Building Climate Rules

Jernkontoret, 30 Oct 2025

Jernkontoret supports a unified system to improve transparency and climate performance across the EU. They advocate for assessments that include the full building life-cycle and recycling benefits.
Harmonized reporting would allow the industry to prove the climate benefits of recyclable steel.

Eurogypsum urges harmonized EU building carbon calculation methodology

Eurogypsum, 31 Oct 2025

Eurogypsum calls for a unified methodology covering the full life cycle to ensure fair competition. They argue that excluding later stages would ignore the benefits of durable and recyclable materials.
A harmonized approach would lower administrative costs and emphasize the value of recyclable gypsum products.
Climate goals are weakened if national governments focus only on initial production emissions.

CELSA Group calls for EU-made steel in building calculations

CELSA Group, 30 Oct 2025

CELSA argues the framework should promote green public procurement by prioritizing low-carbon materials. They request material-specific policies that highlight the environmental performance of European steel.
This would boost demand for CELSA's products while protecting them from international competition.
Non-EU steel manufacturers would face higher barriers when exporting carbon-intensive products to Europe.

Lighting industry urges mandatory acceptance of product-specific emission data

LightingEurope, 30 Oct 2025

The organization requests that the EU mandates Member States to accept product-specific data. They also advocate for using established lighting-specific standards for operational calculations.
Standardized rules would prevent market fragmentation and protect the competitive position of sustainable manufacturers.
Sustainably operating manufacturers lose if generic default values mask their products' superior performance.

Property owners urge simple climate reporting for new buildings

Union Internationale de la Propriété Immobilière - International Union of Property Owners, 28 Oct 2025

UIPI demands a simple, cost-efficient procedure that utilizes existing data instead of creating new burdens. They request a single indicator and simplified rules for small residential buildings.
This would protect property owners from additional bureaucratic costs and investment delays.
Environmental groups lose detailed transparency if product-specific emissions data remains strictly optional.

Architects’ Council of Europe urges mandatory design-stage carbon assessments

Architects' Council of Europe, 31 Oct 2025

The council wants mandatory emissions assessments during the building's design phase. They demand binding minimum requirements and harmonized tools to ensure fair competition. They advocate for freely accessible, machine-readable data to assist smaller architecture firms.
Harmonization reduces administrative burdens while empowering architects to lead sustainable building design.
Manufacturers of construction products may face pressure to produce detailed environmental data.

European Panel Federation urges fair biogenic carbon rules

European Panel Federation, 31 Oct 2025

EPF requests harmonized rules for biogenic carbon and realistic material data. They also seek simplified compliance pathways to reduce burdens for smaller companies.
These rules would protect the competitive position of wood-based construction products.
Producers of high-carbon materials lose competitive advantage against natural, bio-based alternatives.

Woodworking industry demands recognition of biogenic carbon storage

European Confederation of Woodworking Industries, 30 Oct 2025

CEI-Bois requests that carbon stored in wood products be explicitly recognized and reported separately in building assessments. They advocate for dynamic life cycle assessments to reflect the climate benefits of long-lived timber. Additionally, they call for mutual recognition of environmental data across all EU member states.
This would improve wood’s market competitiveness by highlighting its carbon storage benefits.

Consultation response

Etex, 31 Oct 2025

Etex welcomes the European Commissions proposed delegated act on the calculation methodology for the Life-Cycle Global Warming Potential (LCGWP) of buildings. This proposal represents a key milestone in integrating embodied and operational carbon considerations into the Energy Performance…

Consultation response

World Green Building Council, 29 Oct 2025

In April 2025, the World Green Building Council (WorldGBC), on behalf of our Europe Regional Network comprising 26 Green Building Councils (GBCs) with over 5,000 private sector members and seven regional partners submitted a position paper to the European Commission on the Delegated Act amending…

Consultation response

Buildings Performance Institute Europe, BPIE ASBL, 24 Oct 2025

BPIE welcomes the publication of the draft Delegated Act setting out a Union framework for the national calculation of life-cycle GWP of new buildings and is generally supportive of its contents. Harmonisation The main purpose of the EU framework is to create consistency and comparability across…

Eurovent calls for harmonized EU building emission calculation rules

European Committee of Heating, Ventilation, Air Conditioning and Refrigeration Manufacturers, 15 Oct 2025

The industry group requests that product data from Ecodesign regulations be used exclusively for building emission calculations. They urge the EU to prevent national authorities from imposing additional or divergent sustainability reporting requirements.
Harmonized data requirements would reduce administrative burdens and ensure a level playing field.
National regulators lose the authority to impose stricter sustainability information requirements for products.

Consultation response

ASOCIACIÓN ESPAÑOLA DEL ALUMINIO Y TRATAMIENTOS DE SUPERFICIE, 30 Oct 2025

Desde la asociación, damos la bienvenida a la ampliación de la mera eficiencia energética, fundamental pero no suficiente, a la sostenibilidad de los edificios. Entendemos que se ha comenzado por el Potencial de Calentamiento Global, que es sólo el primer y que en el futuro se irá avanzando tal…

Consultation response

Irish Green Building Council, 31 Oct 2025

According to the Commission The mandatory calculation of GWP based on the calculation framework in the delegated regulation creates an incentive to use low-carbon construction materials including clean steel and cement, thereby fostering lead markets for such products, and biobased material such as…

Consultation response

Royal Institution of Chartered Surveyors (RICS), 31 Oct 2025

Please find RICS's feedback attached.

Consultation response

Federation of European Heating, Ventilation and Air-conditioning Associations, 30 Oct 2025

We welcome the overall approach proposed by the Commission in the Delegated Act to advance the harmonization of GWP calculations across Member States. In particular, we agree with other feedback that emphasizes the importance of reducing administrative burdens and ensuring a level playing field in…

Consultation response

Hauptverband der Deutschen Holzindustrie und Kunststoffe verarbeitenden Industrie und verwandter Industrie- und Wirtschaftszweige, 31 Oct 2025

Der Hauptverband der Deutschen Holzindustrie und Kunststoffe verarbeitenden Industrie und verwandter Industrie- und Wirtschaftszweige e.V. (HDH) bedankt sich für die Möglichkeit zur Beteiligung an dem Vorgang und begrüßt das Ziel der Europäischen Kommission, gemäß Artikel 7 Absatz 3 der…

Consultation response

Deutsche Gesellschaft für Nachhaltiges Bauen – DGNB e.V., 31 Oct 2025

Please find attached comments and recommendations by the German Sustainable Building Council (DGNB).

Consultation response

Systemair, 31 Oct 2025

While indispensable for assessing a products impact on the environmental performance of buildings, the calculation of lifecycle GWP of buildings requires a solid standardisation and legislative framework across the EU, which is currently lacking. Legislators should commit to the main and only…

Consultation response

Kiinteistönomistajat ja rakennuttajat Rakli ry - Finnish Property Owners Rakli, 31 Oct 2025

Please see the attached file.

Consultation response

Asociación Nacional de Fabricantes de Materiales Aislantes, 31 Oct 2025

ANDIMAT, the Spanish National Association of Insulation Materials Manufacturers, considers the proposed regulation is a necessary tool for the EPBD purpose. Clarity and homogeneity for the calculation of GWP of new buildings is key to establish values that represent well the reality, and therefore…

Consultation response

UNICLIMA, 31 Oct 2025

Uniclima represents the French manufacturers in heating cooling and ventilation sectors. Uniclima supports the introduction of LCA in the building regulation for new buildings, as it is the case in France from 2022. However, regarding HVAC products which are mainly coverd by ErP regulation (and…

Consultation response

, 31 Oct 2025

The European Federation of Premanufactured Building (EFV) represents national prefabrication associations across Europe and works to unlock the potential of serial, modular, and system-based construction thereby contributing to affordable and sustainable housing across Europe. EFV generally…

Consultation response

Instituut Natuur- en Bosonderzoek/Research Institute for Nature and Forest, 29 Oct 2025

We appreciate the European Commission's work on this important subject. However, in the interpretation of the EN 15978 (EN 15978:2011 Sustainability of construction works) there are inconsistencies on the biogenic carbon of products for the GWP calculations. Now producers are obliged to deduct the…

Consultation response

, 29 Oct 2025

The harmonised EU framework under the revised EPBD for calculating lifecycle GWP of new buildings is timely and welcome. We believe the methodology and guidance should in addition acknowledge that secure bicycle parking is an indirectunusual yet relevantindicator of a buildings climate performance,…

Consultation response

Puutuoteteollisuus ry, 27 Oct 2025

Puutuoteteollisuus ry (Finnish Woodworking Industries Federation) welcomes the proposed Delegated Regulation establishing an EU-wide framework for calculating and disclosing the whole-life Global Warming Potential (GWP) of new buildings. We strongly support the objective of harmonised comparability…

Consultation response

75inQ, 23 Oct 2025

Please find attached the feedback of 75inQ.